Now California has already determined that glyphosate is a carcinogen and falls under Prop 65 provisions. The question is how much exposure would require a warning to the public.

Monsanto was at the public hearing and insisted glyphosate doesn’t cause cancer at all. And they are suing California for finding it does.

Here is my written comment to the OEHHA:

Regarding the “specific regulatory level” of glyphosate, a study published in the journal BioMed Research International revealed the Roundup herbicide to be 125 times more toxic than its “active ingredient”, glyphosate, by itself.

The paper (1) states,“Major pesticides are more toxic to human cells than their declared active principles.” It demonstrates how agrichemical companies conceal the actual toxicity of the poisons they push on farmers by putting out a single ingredient as the “Trojan Horse” —the active ingredient—and from that single chemical determine an “acceptable level of harm” via the calculation of the so-called acceptable daily intake (ADI) based on the toxicological risk profile of only that single ingredient.

Pesticides are used throughout the world as mixtures called formulations. They contain adjuvants, which are often kept confidential and are called “inerts” by the manufacturing companies, plus a declared Active Principle (AP), which is the only one tested in the longest toxicological regulatory tests performed on mammals. This allows the calculation of the Acceptable Daily Intake (ADI)—the level of exposure that is claimed to be safe for humans over the long term—and justifies the presence of residues of these pesticides at “admissible” levels in the environment and organisms.

Only the AP and one metabolite are used as markers. Toxicity in so-called inert adjuvants was up to 10,000 times more toxic than glyphosate itself, revealing them to be a greater source for toxicity than the active ingredient.

(2) This synergistic toxicity explains animal research where glyphosate products were found to be poisonous in the parts-per-trillion range (0.1 part per billion), a value that could not be explained by glyphosate itself.

(3) The researchers noted:“Adjuvants in pesticides are generally declared as inerts, and for this reason they are not tested in long-term regulatory experiments. It is thus very surprising that they amplify up to 1000 times the toxicity of their APs in 100 percent of the cases where they present. In fact, the differential toxicity between formulations of pesticides and their APs now appears to be a general feature of pesticides toxicology. As we have seen, the role of adjuvants is to increase AP solubility and to protect it from degradation, increasing its half-life, helping cell penetration, and thus enhancing its pesticidal activity and consequently side effects. They can even add their own toxicity.”

(4) The definition of adjuvants as “inerts” is thus nonsense; even if the US Environmental Protection Agency has recently changed the appellation for “other ingredients,” pesticide adjuvants should be considered as toxic “active” compounds. According to the researchers, Roundup herbicide is an exemplary illustration of the duplicitous claims made by agrichemical corporations that the chemicals applied to our food are relatively safe and that safety is a scientific fact. It is a pseudoscience “fact” that it is safe. Roundup is 125 times more toxic than glyphosate.

Roundup is one of the most toxic among the herbicides and insecticides tested, and it does not degrade in the environment!

Agrichemical companies will falsify health risk assessments and delay health policy decisions if they can, which is why regulators should not rely on just one study to determine ADI. I am sure there is an interest in not upsetting the apple cart too much, but on a practical level setting the ADI too high is almost meaningless.

Apparently, the European Environmental Agency (EFA) thought so and published a paper, “Late lessons from early warnings,”which cover a diverse range of chemical and technological innovations, and illustrates how damaging and costly is the misuse or neglect of the precautionary principle.

(5) The acceptable daily intake (ADI) of glyphosate is 0.3 ppm (parts per million), but it should be less than 3 ppb (parts per billion) in the context of the Roundup, one of several glyphosate based herbicides, Glyphosate does not degrade, so it just accumulates and builds up just like DDT. The ADI is an assumption based on an assumption.

No testing takes place to determine if the ADI is accurate or isn’t, and in the case of glyphosate, minuscule doses make for some nice endocrine disruption. The ADI measure is an assumption based on current understandings of what toxicity might be from long-term exposure to repeated ingestion of chemical compounds in foods (present and/or added), as opposed to acute toxicity. It is a projection often based on skewed if not truncated or biased research.

In the case of glyphosate there is an ADI but glyphosate is applied with untested co-forumulants that significantly enhance the synergistic toxicities. It makes the ADI for glyphosate itself misleading even if it were accurate.

Ever wonder why so many men have “low T” (hypogonadism), girls are entering puberty at eight years of age, and women are developing breast cancer?

In 2016, it was determined (6) that the endocrine-disrupting effects of all the inert ingredients and co-formulants disrupted aromatase activity, a key enzyme in the balance of sex hormones, below the toxicity threshold and 800 times lower that that used in agricultural dilution. This clearly challenges the relevance of ADI value for active ingredient exposures alone, glyphosate in this example, when the inert ingredients get a free-pass—obviously not inert. It is never just one thing . . . and that is the whole point.

Exposure to a single formulated pesticide must be considered as co-exposure to an AP and the adjuvants. In addition, the study of combinatorial effects of several APs together may be very secondary if the toxicity of the combinations of each AP with its adjuvants [are] neglected or unknown. Even if all these factors were known and taken into account in the regulatory process, this would not exclude an endocrine-disrupting effect below the toxicity threshold. The chronic tests of pesticides may not reflect relevant environmental exposures if only one ingredient is tested alone

Even now, when it’s clear that more research must be done to determine to what degree glyphosate may be carcinogenic, it’s not clear whose responsibility it is to conduct that research.

Should it be the public health agencies of other countries? Should it be independent researchers who just happen to be interested in the causes of non-Hodgkin’s lymphoma, the cancer with which glyphosate is associated?

We don’t need better, smarter chemicals along with the few GMO crops that can tolerate them; we need fewer chemicals and a diverse genetic crop base.

There’s no reason to put the general population, and particularly the farming population, at risk for the sake of industry profits.

Later in 1991, when the agency changed the classification to “not carcinogenic,” three scientists involved in the study refused to sign, and one wrote “do not concur.” The EPA changed the classification because we now exist in a time where there is an unholy alliance between corporation and state in the United States.

But in California there is Prop 65…. nevertheless, what should the daily exposure be allowed to be. Having it set too high mocks the law, having it set at all calls into question why there is not a total ban given it is a carcinogen we can live without.

Eat organic foods as much as possible, but even organic food is now contaminated.
Avoid using Roundup and other chemical herbicides
Avoid consumption of GMO foods.

Support your detox organs (liver/intestines and kidneys in particular, or to do things that remove toxics directly, such as taking glutathione and things that enhance Glutathione transferase activity such as EGCG from green tea. Detox baths such as Epsom salt baths in your hopefully fluoride free water.

And now studies show Monsanto is killing our oceans: “…according to research by the Marine Pollution Bulletin and others, we can add glyphosate, Monsanto’s Roundup Ready herbicide, to the top of the list [killing our oceans and planet]”